Guidelines for Marine Artificial Reef Materials, Second Edition

will be exposed by any of the demolition activities would need to be removed prior to the
demolition. Category II asbestos-containing material may or may not be left in place.. A case-bycase
determination would need to be made for these materials….Where there is a question, EPA
or local delegated agency should use sound judgement concerning the fate of the material in
question.” The current requirements in Florida for state and federally funded reef projects is that
an EPA or Florida Department of Environmental Protection (DEP) air quality specialists or a
designated certified consultant with asbestos experience must conduct an asbestos assessment of a
vessel prior to sinking. Federal regulations which deal with asbestos are 40 CFR Part 61.145
Subpart M and the OSHA regulations in 29 CFR Part 1915.
Lead
Concerns about the presence of lead in primer coat paints of steel hulled vessels and metal bridge
spans have been expressed by reef managers in recent years. Both Florida and South Carolina
sought guidance on this issue. In a letter written on August 23, 2000 by Roland E. Ferry, Coastal
Programs and Nonpoint Source Section, EPA Region 4, to J. Wayne Hall Assistant Environmental
Manager, South Carolina Department of Transportation, Mr. Ferry stated, “The agency [EPA] does
not consider the lead in paints used on vessels deployed as artificial reefs a significant environmental
or human health risk…The lead in the paint should leach at low rates due to the low solubility of
lead in seawater and is not expected to cause a significant adverse impact. In addition, the removal
of lead based paints may cause greater potential for risk of adverse impact to the environment or
human health than if left in place on the structure.” On May 1, 2001 Florida artificial reef
administrator, Jon Dodrill, contacted Dr. Joseph Sekerke with the Florida Department of Health,
Bureau of Environmental Epidemiology. Dr. Sekerke stated that lead paint in a marine environment
would have no adverse human effects and that there was no human health risk. He confirmed that
lead has low solubility in seawater, and stated that it did not bioaccumulate in fish. While there may
be some effect on invertebrate marine organisms that graze directly on the painted surface, he did
not believe toxic effects would be transferred as a risk to humans. However, this should not
preclude removal of visible concentrations of lead such as lead ballast, shielding and fittings.
Fuel and Oil Products
The definition of oil under the Clean Water Act is “oil of any kind or in any form including, but not
limited to, petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes other than dredged
spoil” [Clean Water Act, Section 311(a)(1)]. On vessels, it would be possible to encounter one of
more refined petroleum products such as gasoline, kerosene, medium to heavy weight fuel oils,
lubricating oils and greases. Crude unrefined oil, synthetic oils, and used or contaminated oils might
also be found.
Hazardous waste cleaning standards which seemed appropriate in the early days of MARAD ship
sinking may no longer be appropriate based upon current experience. For example EPA in the early
1970s developed ship cleaning criteria for liberty ships secured under P.L 92-402. One of these
criteria were: “The presence of cosmoline on the walls of fuel tanks can be adequately mitigated by
filling the tanks with water, and bolting and welding the tank hatches closed. Any tanks that will
be ruptured by the explosive charges used to sink the vessel must be free of cosmoline (Source: EPA
Region 4, Atlanta Georgia).” The Liberty ship Joseph L. Meek, sunk off Escambia County, Florida
in 1976, was found 20 years later to be leaking bunker “C” fuel oil from a small corrosion induced
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